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Introducing the βIn Favour Ofβ filter in Case Laws.
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<h1>Article 9: Taxation Adjustments for Associated Enterprises with Shared Management or Control in Double Tax Avoidance Agreement.</h1> Article 9 of the Double Tax Avoidance Agreement between two Contracting States addresses associated enterprises. It stipulates that if an enterprise in one state participates in the management, control, or capital of an enterprise in the other state, or if the same persons are involved in both enterprises, and the commercial or financial conditions differ from those between independent enterprises, any profits that would have accrued to one enterprise but did not due to these conditions may be included in the profits of that enterprise for taxation purposes.